Words and Phrases - "determinable"
2015 Ruling 2015-0589471R3 - Earnout
5-year earnings based earnout for sale of Holdco common shares by Opco to key employee
Background
The corporate Shareholders (with equal shareholdings) of Holdco (a Canadian-controlled private corporation) wish to sell X% of their...
Words and Phrases
determinable| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Safe-Income Determination Time | safe income determination time for a subsequent contemplated annual common share dividend was immediately before that dividend rather than a prior dividend or s. 55(3)(a)(ii) or (v) increase | 654 |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | s. 85(1) rollover available on dirty s. 85 exchange | 92 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | utilization of safe income as earned through a contemplated succession of dividends of all the annual earnings | 203 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | transactions for using s. 7 rules on sale of non-treasury shares | 212 |
27 August 2014 External T.I. 2014-0529221E5 F - Changement de méthode pour déclarer un gain
administrative policy on earnout calculation was not an election
A taxpayer proposed retroactively changing to using the cost-recovery method in accounting for a share sale on an earnout basis (apparently in a...
Words and Phrases
determinable| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | no reassessment to retroactively adopt a different earn-out recognition | 140 |